The Association for Maximum Service Television (MSTV) and the NAB are recommending that the FCC complete the transition to DTV before changing spectrum policy. Because of DTV interference issues, the broadcast organizations urge that any experiments with spectrum avoid tampering with television spectrum "which is subject to so many difficult challenges and burdens over the course of the digital transition."

The MSTV and the NAB said the Commission "should agree that the costs of adding a layer of additional non-conforming uses on top of the digital transition outweigh the benefits. Additional non-conforming uses would make digital interference issues more complex and their resolution more costly."

They said broadcasters' "lack of control over receivers would further magnify transition costs relative to other bands, where service providers control both transmitters and receivers. And because television broadcast services reach 98 percent of the public, curtailment of the DTV transition would cause significant, widespread harm to the public interest. For these reasons, any near-term introduction of additional non-conforming uses or other major spectrum policy changes should be directed to other bands."

The broadcasters said injecting additional uses of already crowded broadcast spectrum would obstruct and burden the transition, slowing its momentum. They recommend that, for now, the FCC should seek to "quantify existing interference in concrete terms." Second, it should, where possible, base interference management decisions -including decisions on whether to allow new devices and technologies to operate in a particular spectrum band - on "actual, measured interference rather than on often inaccurate interference predictions."